The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Ryan Rabalais, currently an Ethics and Compliance Officer at Bechtel Oil, Gas & Chemicals. Rabalais has been Vice President and CCO at both Rowan Companies and Paragon Offshore.
Ryan Rabalais has over two decades of legal and compliance experience in the oil and gas sector, including being a Vice President & Chief Compliance Officer for two different companies with global operations. Ryan has a history of providing practical solutions to the business and managing overall corporate and regulatory compliance programs. His compliance experience includes a particular focus on anti-corruption, sanctions, trade controls and US anti-boycott, with reporting responsibilities to senior management and the Board of Directors of large, publicly traded companies.
In this Episode 3, Ryan relates some of the skill sets he has used in his journey to the CCO chair and while he has been in that position. They include being what Rabalais calls “Compliance wise” that is knowing the nuts and bolts of compliance and compliance programs so that you are a subject matter expert. You should also under how to do compliance; that is, how to design, create and implement a best practices compliance program. You should be able to communicate up and down the chain (here he brings the wisdom of a Marine. Finally, he ends with some thoughts on worldliness.
Tag: CCO
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Ryan Rabalais, currently an Ethics and Compliance Officer at Bechtel Oil, Gas & Chemicals. Rabalais has been Vice President and CCO at both Rowan Companies and Paragon Offshore.
Ryan Rabalais has over two decades of legal and compliance experience in the oil and gas sector, including being a Vice President & Chief Compliance Officer for two different companies with global operations. Ryan has a history of providing practical solutions to the business and managing overall corporate and regulatory compliance programs. His compliance experience includes a particular focus on anti-corruption, sanctions, trade controls and US anti-boycott, with reporting responsibilities to senior management and the Board of Directors of large, publicly traded companies.
In this Episode 2, we discuss the evolution of the compliance role from that of a legal solution written by lawyers for lawyers to the CCO being seen as a part of the business solution. It began with employees seeing the compliance function as The Land of No, populated by Dr. No to something very different today. We also consider the Black Box problem of compliance.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. This month, I visit with Ellen Hunt, Senior Vice President – Audit, Ethics & Compliance Officer.
Ellen is a lawyer, ethics & compliance professional, and chief audit executive. She has extensive management experience in designing, implementing and operating ethics and compliance programs including board governance and reporting, designing ethics education, creating policy management frameworks, managing enterprise and compliance risk processes as well as handling investigations and regulatory inquiries. Utilizing AARP’s enterprise risk management profile, she re-designed how AARP conducts its annual audit planning process to identify audits that relate to the organization’s must significant risks and incorporated the use of data analytics into audit execution.
In this final episode, Ellen visits about what life can look like after you leave the CCO role. What are the types of corporate positions you are skilled for? As ethics and compliance matures, organizations are now seeing risks as positives. The question becomes how you are going to manage that risk for greater profitability; how you will strategically manage risk. We conclude with a discussion of why CCOs need to go onto Boards of Directors and why Boards need compliance expertise to navigate the post Covid-19 world.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. This month, I visit with Ellen Hunt, Senior Vice President – Audit, Ethics & Compliance Officer.
Ellen is a lawyer, ethics & compliance professional, and chief audit executive. She has extensive management experience in designing, implementing and operating ethics and compliance programs including board governance and reporting, designing ethics education, creating policy management frameworks, managing enterprise and compliance risk processes as well as handling investigations and regulatory inquiries. Utilizing AARP’s enterprise risk management profile, she re-designed how AARP conducts its annual audit planning process to identify audits that relate to the organization’s must significant risks and incorporated the use of data analytics into audit execution.
In this episode, Ellen relates what happens when you get into the CCO chair. She emphasized it is a great opportunity. You must determine your highest risks and move to manage those risks. You need to get to know your team, assess their strengths and weakness and conclude how to use those skills. Learn the budgeting process and push for a realistic budget. Finally, get to know your Board and your Compliance Committee or Audit Committee chair.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. This month, I visit with Ellen Hunt, Senior Vice President – Audit, Ethics & Compliance Officer. Ellen is a lawyer, ethics & compliance professional, and chief audit executive. She has extensive management experience in designing, implementing and operating ethics and compliance programs including board governance and reporting, designing ethics education, creating policy management frameworks, managing enterprise and compliance risk processes as well as handling investigations and regulatory inquiries. Utilizing AARP’s enterprise risk management profile, she re-designed how AARP conducts its annual audit planning process to identify audits that relate to the organization’s must significant risks and incorporated the use of data analytics into audit execution.
Ellen like many who are in compliance, came to it by (1) being drafted and (2) from the legal function. When she began, compliance was legalistic, rules-based; largely seen as an insurance policy in case there was a compliance failure. It has changed to a business process and every CCO needs to understand the business of their organization. We explore what skills you need to develop to grow in the compliance profession.
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recent mandate from the CDC that CEOs, CCOs and CFOs certify and attest that each employee who disembarks from a cruise ship has met the CDC requirements to do so, under potential criminal penalty. Three cruise lines, Royal Caribbean, Carnival Cruises, and Norwegian Cruise Line have over 100,000 employees cooped up on ships in US ports. The CDC wants to make certain that when they come on land, it is safe for everyone.
Some of the highlights include:
- What are the CDC requirements?
- Why does the CDC want CEO, CCO and CFO attestation?
- Should these corporate leaders agree to do so?
- What is about the employees on the ships?
- Given that at least 100 cruise ships that set sail after March 4, the first day that a passenger died of Covid-19 while on a cruise stopping in the United States, is this warranted?
- What does it mean for potential liability going forward?
Resources
Matt Kelly blog post, Cruise Lines Face Covid-19 Compliance Squeeze
The role of the CCO has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance, under Hallmark Three of the Ten Hallmarks of an Effective Compliance Program, it focused on the whether the CCO held senior management status and had a direct reporting line to the Board; stating:
In appraising a compliance program, DOJ and SEC also consider whether a company has assigned responsibility for the oversight and implementation of a company’s compliance program to one or more specific senior executives within an organization. Those individuals must have appropriate authority within the organization, adequate autonomy from management, and sufficient resources to ensure that the company’s compliance program is implemented effectively. Adequate autonomy generally includes direct access to an organization’s governing authority, such as the board of directors and committees of the board of directors.
This Hallmark was significantly expanded in both the 2019 Guidance and the FCPA Corporate Enforcement Policy. And in so doing, the DOJ has increased the prestige, authority and role of both the CCO and corporate compliance function. The 2019 Guidance has four general areas of inquiry around the CCO and corporate compliance function. (1) How does the CCO salary and stature within the organization compare to other senior executives within the company. (2) What are the experience and stature of the CCO with an organization? Does the CCO have appropriate training for the role? (3) How much autonomy does the CCO have to report to the Board of Directors? How often do the CCO meet with directors? Are members of the senior management present for these meetings with the Board of Directors or of the Audit Committee? (4) Is the compliance function run by a designated chief compliance officer, or another executive within the company, and does that person have other roles within the company?
Three key takeaways:
- How can you show the CCO really has a seat at the senior executive table?
- What are the professional qualifications of your CCO?
- Does your CCO have true independence to report directly to the Board of Directors?
Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists in the space between what an organization professes and what it does, yet who bears the responsibility for establishing and maintaining an ethical culture? In this series Jay and I will be exploring key aspects of corporate culture, including why it matters, what influences culture, the CCOs role in culture, assessing corporate culture and how to use that information to improve culture. In this Part III, we consider to what extent the Chief Compliance Officer (CCO) should be involved in shaping a culture of ethics and driving ethical behavior.
Highlights include:
- Who bears the responsibility for culture?
- The duty most often falls to the CCO, so both the CCO and the entire compliance function need to be able to coordinate the various inputs and support mechanisms that guide employee behavior.
- The CCO is often the face of the ethics program for the company – kind of the spokesperson for the company who helps to drive behavior.
- In hiring and recruiting, a CCO can create a culture where an organization would only hire the right type of people as employees.
- When managing upward, the CCO has an equally critical mandate through unfettered access to provide information to the Board regarding the compliance and ethics posture at the company, specifically including the culture.
- What are the warning signs of an unethical culture?
- It is up to the CCO to understand and have their finger on what the culture is, where the challenges are and what needs to be done to continually strengthen the culture.
Please join us for Episode 4, where we explore how a company can begin to assess its own culture.
For more information see Jay’s blog post What is the CCO’s Role in Strengthening the Organization’s Culture of Ethics?on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. check out their website here.
In this episode of Trekking Through Compliance, we consider the episode Dagger of the Mind which aired on November 3, 1966, Star Date 2715.1.
The Enterprise makes a supply run to planet Tantalus V, a colony where the criminally insane are confined for treatment. The facility’s director is Dr. Tristan Adams, a psychiatrist famous for advocating more humane treatment of such patients. After the Enterprise delivers supplies and receives cargo from Tantalus, a man emerges from the container taken aboard and assaults a technician. Reaching the bridge, the intruder demands asylum, but Spock subdues him with a Vulcan nerve pinch. In sickbay, the intruder identifies himself as Simon van Gelder, and a computer check reveals that he is not a patient, but Dr. Adams’ assistant.
On the Enterprise van Gelder becomes increasingly frantic, warning that the landing party is in danger. Spock learns that the neural neutralizer can empty a mind of thoughts, leaving only an unbearable feeling of loneliness and that Adams has been using it on inmates and staff to gain total control of their minds.
Kirk decides to test the neutralizer on himself, with Noel at the controls. Adams appears, overpowers Noel, seizes the controls, increases the neutralizer’s intensity, and proceeds to convince Kirk that he has been madly in love with Noel for years. Adams inadvertently reactivates the neural neutralizer, emptying his mind completely, killing him. Back on the Enterprise, Kirk is informed that van Gelder has destroyed the neural neutralizer. McCoy is surprised that loneliness could be lethal, but Kirk, after his experience, is not.
Compliance Takeaways:
- Be careful at Christmas parties.
- How do you test new protocols?
- How you treat your direct reports is critical for your success as a CCO.
Resources
On this episode of Great Women in Compliance, Lisa Fine speaks with Stacey Hanna, General Counsel, Ethics & Compliance at Lonza, which is an integrated solutions provider in the areas of pharma and biotech, and is headquartered in Switzerland. While Stacey started as an attorney, she was in the mergers and acquisition world, and how this influences her approach to ethics and compliance. She discusses the evolution of her organization’s compliance program and how she works to promote business growth, discussing some real-life examples and strategies to build relationships as a compliance officer. Stacey also discusses evolution in other areas, including work and life complimenting one another and in the compliance space as a whole.
